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U.S. CattleTrace Submits Comment on RFID Proposal

On behalf of our producer participants and industry partners, U.S. CattleTrace appreciates the opportunity to provide feedback on the future of animal disease traceability in the U.S. cattle industry. U.S. CattleTrace is a national organization focused on the development of a disease traceability infrastructure, and we strongly support the proposed transition to EID as official identification for interstate cattle movement. One critical factor in a disease traceability infrastructure for beef producers is that the system operates at the speed of commerce. Since our inception in 2018, U.S. CattleTrace has supported the use of EID technology to achieve that producer priority to ensure a national disease traceability infrastructure does not impede the natural flow of business and we urge USDA to adopt the proposed transition.

While metal tags and brands have historically provided a level of traceability in the cattle industry, they are not a 21st century solution to a challenging issue in a dynamic industry. U.S. CattleTrace identified EID and emerging technologies as tools to accomplish disease traceability for the following reasons: the ability to trace animal movements through the beef supply chain at the speed of commerce, opportunities to allow for value-added programs and expanded marketing capabilities, and the ability to trace animals from birth to tag retirement when the animal is harvested.

Speed of Commerce

U.S. CattleTrace was established as an initiative to bring a solution to the beef cattle industry, by the beef cattle industry. Our decisions are based on direct feedback from the very producers putting tags in calves’ ears and installing reader networks within their operations. One of the most frequent and common pieces of producer feedback was the need for a hands-free system that would not disrupt the current speed of commerce required for day-to-day operations within auction markets, feedyards and cattle harvest and beef processing facilities. Over the course of the last 30 years, many segments of the industry have established use of low-frequency RFID technology. In more recent years, the emergence of ultra-high frequency (UHF) technology has allowed segments of the supply chain to collect data without disruption to daily operations.

In addition to allowing for the collection of animal movement data at the speed of commerce, the implementation of EID could allow for a more rapid return to normal operations in the case of an animal disease outbreak. In the current U.S. CattleTrace model, the Kansas Animal Health Commissioner, as a partner in the original CattleTrace pilot project, demonstrated the ability to conduct more timely traces as compared to paper-based investigations. Further, producers whose cattle are not affected, and can be ruled out based on movement data in the U.S. CattleTrace database, could resume normal operations with significantly less disruption.

Value-Added Opportunities

U.S. CattleTrace has witnessed producers utilize EID technology not only to assist in building an animal disease traceability infrastructure, but also to streamline their daily operations. A Kansas ranching family has utilized the EID tags, specifically, UHF tags, to track inventory on their livestock for the Sandhills Calving System. This is but one example of an innovative producer using EID technology for multiple purposes. U.S. CattleTrace sees many opportunities to use EID technology not only to trace movement for disease traceability purposes but to add value throughout the beef supply chain – from inventory management systems to tracking different production practices or marketing claims, and more.

Building a nationally significant disease traceability infrastructure will take collaboration among all industry producers and stakeholders, including USDA. The agency’s recognition of EID technology as an official form of identification will allow for disease traceability entities, like U.S. CattleTrace, to more seamlessly collaborate with private value-added enterprises, allowing us to build on a unified tag with matching technology to fulfill industry needs.

Birth to Harvest Tracking

Working in tandem with the 2018 USDA goal to “enhance the ability to track animals from birth to slaughter through a system that allows tracking data points to be connected,” EID technology provides U.S. CattleTrace with the means to collect four unique data points, including GPS coordinates, time, date, and individual ID number. These data points allow for contact tracing to occur at points of commingling. The data is kept in a private database, with animal health officials being granted requested information upon approval of a producer-led board in the case of an animal disease outbreak.

U.S. CattleTrace has worked with industry partners to determine optimal placing of the equipment and troubleshoot issues related to EID equipment, which has resulted in higher accuracy of read rates within various segments of the industry. These reads are a crucial starting point in building the disease traceability infrastructure. However, if we are going to develop a nationally significant disease traceability system for the U.S. beef cattle industry, we cannot continue exempting cattle under the age of 18 months. Most cattle, either for feeding or breeding, will move from their ranch of origin within their first 18 months of age. This may include from ranch to ranch or to a stocker operation, finishing feedyard and finally to a harvest facility. Along the way they can transfer ownership and pass though auction markets or other commingling locations. Being able to trace these movements and points of commingling will be paramount in stopping disease spread. We continue to urge USDA to embrace voluntary animal disease traceability through progression of EID implementation for all classes of cattle.

900 Series Tags

There is currently a considerable amount of acceptance and use of 900 series tags for operational uses within various segments of the industry. There is a current concern that 900 series tags allow for duplication of ID’s amongst tag manufacturers. The success of an EID traceability system depends on successful collaboration at all levels. U.S. CattleTrace encourages USDA to develop a framework by which all currently used EID tags could be used as official identification for cattle for animal disease traceability.


In the past, producers have become accustomed to having official ID provided to them at little cost for use within replacement heifers for breeding. Over the course of the last few years, APHIS has provided low-frequency (LF) RFID tags at no cost as an alternative to the metal clip tags that have been utilized when vaccinating heifers for brucellosis. We strongly encourage APHIS to provide EID tags at no-cost or minimal cost to producers within the first two years of implementation of the rule.


U.S. CattleTrace strongly supports USDA’s proposed transition to recognize EID as the form of official identification in cattle and look forward to working with APHIS and the USDA to implement EID technology. Thank you for the opportunity to comment.


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